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Trading Point of Financial Instruments Ltd operating under the trading name XM.com is a Cypriot Investment Firm ("CIF") registered with the Registrar of Companies in Nicosia under number: HE 251334, and regulated by the Cyprus Securities & Exchange Commission ("CySEC") under license number 120/10 (hereinafter called the “Company”). The Company is operating under Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC, as the same may be in force from time to time and modified or amended from time to time (the “Markets in Financial Instruments Directive (2004/39/EC)” or “MiFID”).

As such, the Company is required to comply with Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing, as implemented in Cyprus law by Cyprus Law No. 188(I)/2007 and Cyprus Law No. L58(I)/2010 on the prevention and suppression of money laundering and terrorist financing, as the same may be in force from time to time and modified or amended from time to time.

Preventing money laundering is a major responsibility and aim of regulatory authorities worldwide. Money laundering allows movement of funds from criminal activities and makes funds available for terrorist activities.

At the Company, we are committed to prevent any money laundering activities through our services and as such comply with regulatory requirements such as:

• Identifying our clients; • Identifying, monitoring and reporting any kind of suspicious transactions; • Maintaining transaction records for minimum 5 years after the termination of our contractual

relationships with our clients; • Training our staff to recognize suspicious transactions and to fulfill all reporting obligations; • Depending on client location, report any suspicious activities to authorities in several countries.

The Company reserves the right to collect and validate proof of identification from its clients prior to account opening and any payments of proceeds. In order to verify our identification requirements, please consult the statements on our ‘Account Opening Form(s)’.

Clients should assume that all information provided to the Company is available to the competent regulatory authorities in (a) the country of incorporation of the Company, i.e. the Republic of Cyprus; (b) the country of origin of any funds transmitted to the Company; and (c) the destination country of any funds refunded by or withdrawn from the Company.

The Company reserves the right to refuse to process a transfer of funds at any stage if it believes it to be connected in any way to criminal activities or money laundering.

The Company is obliged to report all suspicious transactions and is prohibited from informing the client that they have been reported for suspicious account activity. Account misuse may result in criminal prosecution.

   

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The Company does not want your business if your funds are sourced from criminal activities or if the nature of your account transactions is illegal in any manner whatsoever.

The Company reserves the right to review and/or amend its Money Laundering Prevention Policy, at its sole discretion, whenever it deems fit or appropriate.

Our Money Laundering Prevention Policy is a policy only, it is not part of our Terms and Conditions of Business and is not intended to be contractually binding or impose or seek to impose any obligations on us which we would not otherwise have, but for Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing and Cyprus Law No. 188(I)/2007 and Cyprus Law No. L58(I)/2010 on the prevention and suppression of money laundering and terrorist financing, as the same may be in force from time to time and modified or amended from time to time.

Should you have a question about our Money Laundering Prevention Policy please direct your questions to our Compliance Department: compliance@xm.com.